Thank you for the
opportunity to comment on the revised risk assessments and related documents
for the triazine pesticide, atrazine. These comments are submitted on
behalf of Beyond Pesticides and its membership. Beyond Pesticides is an
organization committed to pesticide safety and the adoption of alternative
pest management strategies that reduce or eliminate a dependency on toxic
chemicals. To that end, we would like to use this opportunity to comment
on risk mitigation measures for atrazine.

I. Atrazine Poses
Unreasonable Risks to Human Health

Atrazine is the most
widely used herbicide in the United States and applied by farmers in the
Midwest and used in residential lawn management in much of the southeastern
U.S. Due to the dangers on humans and the environment associated with
its routine use and production, atrazine must be immediately banned and
all tolerances revoked. Some of these dangers are as follows:

Atrazine is a Powerful
Endocrine Disruptor

· Hayes et
al. found that at levels commonly found in rivers, atrazine causes sexual
hermaphroditic deformities in frogs.
· Pesticides at low concentrations interfere with the production
and activity of sex hormones in salmon, causing decreases in the production
of sperm.
· Porter et al. found synergistic effects in mice exposed to aldicarb,
atrazine, and nitrate at levels of contamination within the range often
encountered in U.S. water supplies.

U.S. EPA
PAGE TWO
July 3, 2002A

· USGS National
Water Quality Assessment Study found alterations in sex steroid hormones
and vitellogenin in blood of wild carp that appear to be related to certain
chemical groups including atrazine disolved in river water.

Atrazine Causes Cancer
in Rats and is Linked with Cancer in Humans

· Atrazine
has been shown to cause cancer in the mammary glands of rats.
· Studies have linked atrazine exposure to breast cancer in human
females.
· Donna et al. found that woman exposed to triazine pesticides
had an elevated relative risk (RR) of 2.7 for malignant epithelial ovarian
tumors.
· A study conducted by Syngenta found a statistically significant
increase in prostate cancer among longtime workers at its St. Gabriel
LA atrazine production facility.
· Several studies have found a possible risk for Non-Hodgkin's
lymphoma to be associated with atrazine exposure.

II. Risk Mitigation
Measures for Atrazine Use

Any continued use
of atrazine must be strongly controlled and total consumption must be
reduced. Suggestions for measures that would reduce potential exposure
to atrazine and therefore reduce risk are as follows:

· Children
face unnecessary exposure to atrazine when applied to lawns.

U.S. EPA
PAGE THREE
July 3, 2002

· In 1990, the EPA classified atrazine as a Restricted Use Pesticide
(RUP), which included label amendments that reduced application rates
for agricultural uses and limited the maximum annual application rate
for industrial weed control. It also restricts the sale and use to certified
applicators or persons under their direct control.
· Even as an RUP atrazine containing lawn care products can still
be purchased over the counter for unsupervised residential use.
· Home use cannot be monitored for safe use or handling.
· A Minnesota Department of Agriculture survey discovered that
lawn herbicides were found in 80% of the storm runoff events sampled between
April and October.

III. Alternatives
to Atrazine are Widely Available
The continued use of atrazine represents an "unreasonable risk to
man or the environment" when "taking into account the economic,
social, and environmental costs and benefits of the use" of the pesticide.
(Federal Insecticide, Fungicide and Rodenticide Act [(FIFRA), Sections
2(bb) and 3(c)5(D)] Given the availability of alternative pest management
practices that incorporate alternative cultural practices and/or less
toxic pest management products, including other registered pesticides,
the agency has a statutory duty to revoke all registrations of atrazine
products. To the extent that EPA assumes the benefits of atrazine in the
marketplace, the agency is not fulfilling its statutory and regulatory
duty to evaluate benefits in light of risk criteria being exceeded. Certainly,
a review of the literature and an inventory of field experience in integrated
pest management and organic agriculture evidence the viability of alternative
practices that do not use atrazine. If EPA is unable to access this literature
and field experience, Beyond Pesticides/NCAMP would be happy to assist
in this process. Suffice it to say, EPA fails to meet its legal responsibility
under FIFRA in this case if it allows any continued use of atrazine without
making a showing that alternatives to atrazine are not viable.

Under the Food Quality
Protection Act (FQPA), EPA is prohibited from issuing any tolerances for
atrazine if the chemical exceeds the "reasonable certainty of no
harm" standard. The data cited here, in other public comments, and
in other literature not cited here show that atrazine exposure in the
aggregate, and in combination with other chemicals that have a common
mechanism of effect, exceed the risk criteria established by the law.
EPA's own description of FQPA states the following:
U.S. EPA
PAGE FOUR
July 3, 2002

Health-Based Safety
Standard for Pesticide Residues in Food
The new law [FQPA] establishes a strong, health-based safety standard
for pesticide residues in all foods. It uses "a reasonable certainty
of no harm" as the general safety standard:
· Sets a single, health-based standard, which eliminates longstanding
problems posed by multiple standards for pesticides in raw and processed
foods;
· Requires EPA, when setting tolerances, to consider all non-occupational
sources of exposure, including drinking water, and exposure to other pesticides
with a common mechanism of toxicity.

Thank you for this
opportunity to comment on the revised risk assessments and related documents
for the triazine pesticide, atrazine, and, for your consideration of the
substantive points made above. We expect that EPA will carry out its statutory
and regulatory responsibility and move to cancel the registration of atrazine,
including all formulations that contain atrazine, and revoke all atrazine
tolerances. We further expect that EPA will take the utmost care in protecting
our health and the health of our environment.